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Verizon enrolls customers by default in the Custom Experience and Custom Experience Plus programs, which use network-level browsing history and app usage data to build advertising profiles used for targeted marketing across Verizon business lines. Customers must actively opt out to exit these programs.
This analysis describes what Verizon's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision establishes a default opt-in enrollment for a program that uses network-level data, including URLs visited and app usage, for advertising profiling. Under FCC CPNI rules, telecommunications carriers have historically been subject to restrictions on using certain network usage data for marketing without affirmative customer consent, and this default enrollment structure may require evaluation against those requirements.
Interpretive note: The relationship between this default enrollment structure and FCC CPNI consent requirements is not resolved in the document, and regulatory treatment may depend on FCC enforcement posture and how 'network usage data' is classified under CPNI rules.
The new version explicitly states automatic enrollment with opt-out requirement, whereas the previous version did not clearly disclose the default enrollment status.
View full change record →Under this clause, customers' network browsing and app data are used to build advertising profiles unless the customer actively opts out of the Custom Experience Plus program through account settings or by contacting Verizon. The provision identifies the data involved as wireless network browsing activity and app usage information.
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"Custom Experience uses your wireless network browsing and app data to give you a personalized experience with us. Custom Experience Plus uses your wireless network browsing and app data to provide you personalized experiences across our business lines and improves marketing so you see ads from us that are more relevant to you. You are automatically enrolled in these programs unless you opt out.Excerpt from Verizon's Privacy Policy (Summary)
1) REGULATORY LANDSCAPE: This provision directly implicates FCC Customer Proprietary Network Information rules, which restrict how telecommunications carriers may use call detail records and network usage data for marketing purposes. The FTC Act's prohibition on unfair or deceptive practices also applies to default enrollment disclosures. Under CCPA and CPRA, use of browsing and app data for cross-context behavioral advertising may constitute 'sharing' requiring a Do Not Sell or Share opt-out mechanism. The FCC and FTC are the primary enforcement authorities. 2) GOVERNANCE EXPOSURE: High. The default enrollment structure for a program using network-level browsing and app data for advertising creates exposure under FCC CPNI rules, which have historically required affirmative opt-in consent for certain marketing uses of network usage data. The breadth of data involved, including URLs visited and app usage at the network layer, distinguishes this from standard behavioral advertising practices at the application level. 3) JURISDICTION FLAGS: California residents have CPRA rights to opt out of sharing for cross-context behavioral advertising, and this program may qualify as such sharing. The FCC CPNI framework applies nationally to wireless customers. Exposure is heightened for California residents given CPRA enforcement by the California Privacy Protection Agency. 4) CONTRACT AND VENDOR IMPLICATIONS: Procurement and compliance teams should assess whether Custom Experience Plus data flows to advertising technology partners or affiliates and whether those data flows are covered by appropriate data processing agreements. The policy does not specify the full list of advertising partners receiving this data. 5) COMPLIANCE CONSIDERATIONS: Legal teams should evaluate whether the default enrollment model is consistent with FCC CPNI consent requirements, assess the adequacy of the opt-out mechanism disclosure, and confirm that the program's data flows are accurately reflected in data mapping documentation. CPRA compliance teams should assess whether this program's sharing constitutes 'sale or sharing' under California law.
Regulatory citations, enforcement risk, and due diligence action items.
Ad personalization controls removed. Contact scanning added. Advertiser data partnerships quietly dropped. A timeline of every change.
Provision-level monitoring, governance timelines, and regulatory mapping built from archived source documents and historical version tracking.
This provision establishes a default opt-in enrollment for a program that uses network-level data, including URLs visited and app usage, for advertising profiling. Under FCC CPNI rules, telecommunications carriers have historically been subject to restrictions on using certain network usage data for marketing without affirmative customer consent, and this default enrollment structure may require evaluation against those requirements.
Under this clause, customers' network browsing and app data are used to build advertising profiles unless the customer actively opts out of the Custom Experience Plus program through account settings or by contacting Verizon. The provision identifies the data involved as wireless network browsing activity and app usage information.
ConductAtlas has identified this type of provision across 295 platforms. See the full comparison.
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